AN APPROACH FOR EVALUATING NUMERIC WATER QUALITY CRITERIA
                  FOR WETLANDS  PROTECTION
                            by

           Cynthia A.  Hagley  and  Debra  L.  T.aylor
                     Asci Corporation
                 Duluth, Minnesota  55804
                      Project  Officer

                    William D.  Sanville
                      Project Leader
            Environmental  Research Laboratory
                 Duluth, Minnesota  55804
                         DU:   BIOL
                         ISSUE:   A
                         PPAi  16
                       PROJECT:  39
                    DELIVERABLE:  8234
                       July 6, 1991

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                             ABSTRACT


     Extension of the national numeric aquatic life criteria to
wetlands has been recommended as part of a program to develop
standards and criteria for wetlands.  This report provides an
overview of the need for standards and criteria for wetlands and
a description of the numeric aquatic life criteria.  The numeric
aquatic life criteria are designed to be protective of aquatic
life and their uses for surface waters, and are probably
applicable to most wetland types.  This report provides a
possible approach, based on the site-specific guidelines, for
detecting wetland types that might not be protected by direct
application of national numeric criteria.  The evaluation can be
simple and inexpensive for those wetland types for which
sufficient water chemistry and species.assemblage data are
available, but will be less useful for wetland types for which
these data are not readily available.  The site-specific approach
is described and recommended for wetlands for which modifications
to the numeric criteria are considered necessary.  The results of
this type of evaluation, combined with information on local or
regional environmental threats, can be used to prioritize wetland
types (and individual criteria) for further site-specific
evaluations and/or additional data collection.  Close
coordination among regulatory agencies, wetland scientists, and
criteria experts will be required.

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                             CONTENTS


Abstract
Tables
Acknowledgements                                               iv

      1.  Introduction                                           1
               Need .for standards for wetlands                  1
               Proposed approach to 'development of vetland
                    standards                                   3
               Purpose of this document                         4
      2.  Current Surface Water standards and Criteria           6
               Description of standards and criteria            6
               Development of national aquatic life numeric
                    criteria                  •               •   7
               Site-specific guidelines                         8
      3.  The Need for Evaluating Numeric Water
          Quality Criteria:  Use of the Site-Specific
          Guidelines                                            9
               Overall relevance of criteria to wetlands        9
               Wetland variability                             10
               Use of the site-specific guidelines for
                    wetlands                                   10
               Aquatic plants                                  14
     4.   Evaluation Program                                    16
               Classification                                  16
               Evaluating the appropriateness of direct
                    application of criteria                    17
               Developing site-specific criteria               18
     5.   Example Analyses                                      19
               Example 1                                       19
               Example 2                                       21
               Summary of the example analyses                 24
     6.   Conclusions                                           26

References                                                     28
Appendices

     A.   Sources used in species habitat identification
               for Minnesota marshes                           31
     B.   Sources used in species habitat identification
               for prairie potholes                            32
                                ii

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                           TABLES
1  Freshwater numeric aquatic life criteria                33

2  Suitability of wetland species to fill minimum
   family requirements for six criterion chemicals         34
                                   •»
3  Some conditions recommended for dilution water
   for water quality criteria testing                      35

4  Effects of cof actors on criterion chemical toxic ity     36

5  Water chemistry for selected Minnesota marshes          37

€  Comparison of test species with Minnesota marsh
   biota for six criterion chemicals                       38

7  Number of species tested for acute criteria and
   percentage of test species that are not found in
   Minnesota marshes or oligosaline prairie potholes       40

8  Water quality characteristics for oligosaline
   prairie potholes                                        41

9  Comparison of test species with prairie pothole
   biota for six criterion chemicals                       42
                             111

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                        ACKNOWLEDGEMENTS


     Preparation of this document has been funded by the U.S.
Environmental Protection Agency.  This document has been prepared
at the EPA Environmental Research Laboratory in Duluth,
Minnesota, through Contract # 68033544 to AScI Corporation.  This
document has been subjected to the Agency's peer and
administrative review.   Excellent reviews and assistance were
received from C. Stephan,  R. Spehar, *C. Johnston, E. Hunt, D.
Robb, and J. Minter.
                                IV

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                            SECTION  1

                           INTRODUCTION


NEED FOR STANDARDS  FOR WETLANDS

      Wetlands have  been studied.and  appreciated for a relatively
short time  in relation to other types of aquatic systems.  The
extent of their value in the landscape has only recently been
recognized;  in fact, a few decades ago government policies
encouraged  wetland  drainage and conversion.  Wetlands
traditionally have  been recognized as important fish and wildlife
habitats, and it is estimated that over one-third of U.S.
endangered  species  require wetland habitat for their continued
existence.   Some of their many other values, however, have become
apparent  only recently.  These include attenuation of flood
flows, groundwater  recharge, shoreline and stream bank
stabilization, filtering of pollutants from point and nonpoint
sources,  unique habitats for both flora and fauna, and
recreational and educational opportunities.1

Impacts to Wetlands

     Despite new appreciation of the valuable functions that
wetlands  perform in the landscape, they continue to be destroyed
and altered at a rapid pace.  Since pre-settlement times over
half of the wetlands in the continental U.S. have been destroyed,
and losses over the last few decades have remained high.2  These
figures only represent actual loss of acreage and do not account
for alterations to or contamination of still-extant wetlands.
The causes of wetland destruction and degradation include:3

     *    Urbanization - Resulting in drainage and filling,
          contamination,  and ecological isolation of wetlands.

     *    Agriculture Conversion - Drainage, cropping, and
          grazing which change or destroy wetland structure and
          ecological function.

     *    Water Resource Development - Water flow alterations to
          wetlands from diking, irrigation diversions,
          alterations to rivers for navigation, diversions for

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          water supply, and groundwater pumping.  These result in
          changes in the hydrology that sustains the wetland
          system.

      *    Chemical Pollution - From point and nonpoint sources,
          hazardous waste sites, mining, and other activities.
          These can overwhelm the assimilative capacity of
          wetlands or be toxic to wetland organisms.

      *    Biological Disturbances - Introduction or elimination
          of plant and animal species that affect ecosystem
          processes.

Gaps  in Federal Regulatory Programs *.

      Existing Federal regulatory programs intended to reduce some
of the impacts described above leave major gaps in the protection
of wetlands.  Section 404 of the Clean Water Act (CWA) requires a
permit to be obtained from the Army Corps of Engineers, in
cooperation with the U.S. Environmental Protection Agency (EPA),
before dredged material or fill can be discharged into waters of
the United States.  Alterations such as drainage, water
diversion, and chemical contamination are not covered by Section
404 unless material will be discharged into the wetland in
association with such alterations.  The Resource Conservation and
Recovery Act, which regulates the disposal of hazardous wastes,
and the CWA, which regulates contamination from waste-water
discharges and nonpoint-source pollution, could provide
protection from certain impacts, but they have not been used
consistently to regulate impacts to wetlands.  Programs designed
to protect endangered species, migratory birds, and marine
mammals have also been used to reduce impacts to wetlands, but
"the application of these programs also has been uneven."*

Gaps in State Regulatory Programs

   .  Wetland regulations vary greatly among states.  Some States
are now developing narrative standards for wetlands (e.g.
Wisconsin, Rhode Island, and others).  On the other hand,
although wetlands are included in the Federal definition of
"waters of the United States" and are protected by Section 101(a)
of the CWA,  not all States include them as "waters of the State"
in their definitions.  A review conducted in 1989 by the EPA
Office of Wetlands Protection and the Office of Water Regulations
and Standards found that only 27 of SO States mentioned wetlands
in definitions of State waters.  The review verified that there
generally is a lack of consideration given to water quality
standards for wetlands.5

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 Effective Use of Fxiatina Regulatory Options

      Although some impacts (e.g. excavation, most drainage, and
 destruction  of vegetation)  are not addressed by  the  current
 implementation of existing regulations and programs, much of the
 chemical  contamination of wetlands could be controlled through
 existing  Federal and state water pollution control laws.*  The
 National  Wetlands Policy Forum recommended that  EPA  and State
 water pollution control agencies review the implementation of
 their water  quality programs to ensure that the  chemical
 integrity of wetlands is adequately protected.   The  Forum
 stressed  the need to develop water quality standards designed to
 protect sensitive wetlands.
                                     *
      Under Section 401 of the CWA, States have authority to
 authorize, condition,  or deny all Federal permits or licenses in
 order to  comply with state  water quality standards,  including,
 but not limited to,  Sections 402 and 404 of the  CWA, Sections 9
 and 10 of the Rivers and Harbors Act, and Federal Energy
 Regulatory Commission licenses,  states with water quality
 standards-that apply to or  are specifically designed for wetlands
 can use. 401  certification much more effectively  as a regulatory
 tool.  •

      As wetlands  receive more recognition as important components
 of State  water resources, the need for testing the applicability
 of some existing  guidelines and standards to wetlands regulation
 becomes more  apparent.


 PROPOSED  APPROACH TO  DEVELOPMENT OF WETLAND STANDARDS

     The  EPA  Office of Water Regulations and standards and Office
 of Wetlands Protection  recently completed a document entitled,
 "National Guidance:  Water Quality standards for Wetlands."6  It
 recommends a  two-phased  approach for the development of water
 quality standards for wetlands.  In the first 3-year phase of
 this program,  standards  for wetlands would be developed using
 existing  information in  order to provide protection to wetlands
 consistent with the protection afforded other State waters.
 Technical support for this initial phase will be provided through
 documents such as this one, which focuses on the application of
 existing  numeric criteria to wetlands.   These criteria are widely
 used.   Applying them to wetlands requires a small amount of
 effort and can be accomplished quickly.

     The development of narrative biocriteria is also required in
the initial phase of standards development.  The long-term goal
 (3-10 years)  of this program is to develop numeric biocriteria
 for wetlands.  It is anticipated that both narrative and numeric

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 biocriteria can provide a more integrative estimate of whole-
 wetland health and better identification of impacts and trends
 than can be attained by traditional numeric chemical criteria.
 Field-based, community-level biosurveys can be implemented to
 complement, and help validate, laboratory-based conclusions.
 Results of such surveys can be used to monitor wetlands for
 degradation and establish narrative or numeric biocriteria or
 guidance which take into account "real world11 biological
 interactions and the interactions of multiple stressors.

     More information on the development of numeric biocriteria
 will be available in a guidance document in coming years.
 Technical guidance to support the development of biological
 criteria for wetlands has also been prepared.7 This guidance
 provides a synthesis of technical information on field studies of
 inland wetland biological communities.


 PURPOSE OF THIS DOCUMENT

     A number of steps are needed to develop wetland standards.
 The document, "National Guidance:  Water Quality Standards for
 Wetlands," mentioned above,  provides general guidelines to the
 States for each of the following steps:  the inclusion of
 wetlands in definitions of State waters, the relationship between
 wetland standards and other water-related programs, use
 classification systems for wetlands, the definition of wetland
 functions and values,  the applicability of existing narrative and
 numeric water quality criteria to wetlands, and the application
 of antidegradation policies to wetlands.

     The technical document for biological criteria7 and this
 report are companions to the guidance document described above.
 This report is directed primarily toward wetland scientists
 unfamiliar with water quality regulation and is intended to
 provide a basis for dialogue between wetland scientists and
 criteria experts regarding adapting numeric aquatic life criteria
 to wetlands.  More specifically:

     1)  It provides background information and an overview of
 water quality standards and numeric chemical criteria, including
 application to wetlands.

     2)  The need for evaluating numeric water quality criteria is
discussed.   The site-specific guidelines are introduced and
discussed in two contexts:  a) as an initial screening tool to
ensure that water quality in extreme wetland types is adequately
protected by criteria,  and b)  in terms of using the site-specific
guidelines to modify criteria for wetlands where criteria might
be over or underprotective.

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     3) An approach is described that uses information available
from criteria documents and is designed to: a) detect wetland
types where water quality is not clearly protected by existing
criteria, and b) help prioritize further evaluations and research
efforts.

     4)  A simple test of the approach is presented with two
examples.  Results are not considered conclusive and are
presented only as an example of the procedure.

     Most of the data and examples are based on the freshwater
acute criteria.  A similar approach should be equally applicable
to the saltwater acute criteria and to both saltwater and
freshwater chronic criteria.

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                            SECTION 2

           CURRENT SURFACE  WATER STANDARDS AND CRITERIA


     This section describes how criteria are used in State
standards, how national numeric criteria are derived, and what
options are currently available for modifying national aquatic
life criteria.


DESCRIPTION OF STANDARDS AND CRITERIA

     Surface waters are protected by Section 101(a)  of the CWA
with the goal:  "to restore and maintain the chemical, physical,
and biological integrity of the nation's waters."  State water
quality standards are developed to meet this goal.

State Standards

     There are two main components to establishing a standard:
1) The level of water quality attainable for a particular
waterbody, or the designated use of that waterbody (e.g.
recreational, fishery, etc.) is determined;   2)  Water quality
criteria (usually a combination of narrative and numeric) are
established to protect that designated use.   Water quality
standards also contain an antidegradation policy "to maintain and
protect existing uses and water quality, to provide protection
for higher quality waters,  and to provide protection for
outstanding national resource waters."*  State standards for a
particular waterbody must be met when discharging wastewaters.
The "National Guidance:  Water Quality Standards for Wetlands"6
outlines a basic program to achieve these goals for wetlands.

Aquatic Criteria

Narrative Criteria—
     Narrative criteria are statements, usually expressed in a
"free from ..." format.  For example, all States have a narrative
statement in their water quality standards which requires that
their waters not contain "toxic substances in toxic amounts."
Narrative criteria are typically applied at the State level when
combinations of pollutants must be controlled or when pollutants
are present which are not listed in State water quality

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 standards.8  States must document the process by which they
 propose  to  implement  these narrative criteria in their standards.

 Numeric  Criteria—
      Pollutant-specific numeric criteria are used by the States
 when  it  is  necessary  to control individual pollutants in order to
 protect  the designated  use of a waterbody.  Fate and transport
 models commonly are used to translate these criteria into permit
 limits for  individual dischargers.  Some criteria apply State-
 wide  and others are specific to particular designated uses or
 waterbodies.

      National numeric criteria are developed by EPA based on best
 available scientific-  information.  They serve as recommendations
 to assist States in developing their own criteria and to assist
 in interpreting narrative criteria.9  These include human health
 and aquatic life pollutant-specific criteria and whole effluent
 toxicity criteria.  Sediment criteria are now being developed.
 States can  adopt national numeric criteria directly.
 Alternatively, site-specific criteria may be developed using EPA-
 specified guidelines, and State-specific criteria can be derived
 using procedures developed by the State.8


 DEVELOPMENT OF NATIONAL AQUATIC LIFE NUMERIC CRITERIA

      National aquatic life criteria are usually derived using
 single-species laboratory toxicity tests.  Tests are repeated
 with  a wide variety of  aquatic organisms for each chemical.  The
 criteria are designed to protect against unacceptable effects to
 aquatic organisms or  their uses caused by exposures to high
 concentrations for short periods of time (acute effects), to
 lower concentrations  for longer periods of time (chronic
 effects), and to combinations of both.9   EPA criteria  are
 composed of 1) magnitude (what concentration of a pollutant is
 allowable) ; 2) duration of exposure (the period of time over
which the in-stream concentration is averaged for comparison with
 criteria concentrations); and 3) frequency (how often the
 criterion can be exceeded without unacceptably affecting the
 community).10  Separate  criteria are determined for fresh water
 and salt water.  Field data are used when appropriate.

     All acceptable data regarding toxicity to fish and
 invertebrates are evaluated for inclusion in the criteria.  Data
on toxicity to aquatic plants are evaluated to determine whether
 concentrations of the chemical that do not cause unacceptable
effects to aquatic animals will cause unacceptable effects to
plants.  Bioaccumulation data are examined to determine if
residues in the organisms might exceed FDA action levels or cause
known effects on the wildlife that consume them.  For a complete

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 description of the procedures for deriving ambient criteria,
 consult the "National Guidelines'* (1985).*

     Numeric water quality criteria are designed to protect most
 of the species inhabiting a site.9  A wide variety of taxa with a
 range of sensitivities are required for deriving criteria.
 Guidelines are followed to determine the availability of
 sufficient experimental data from enough appropriate taxa to
 derive a criterion.  For example, to derive a freshwater Final
 Acute Value for a chemical, results of acute tests with at least
 one species of freshwater animal in at least eight different
 families are required.  Acute and chronic values can be made to
 be a function of a water quality characteristic such as Ph,
 salinity, or hardness, when it is determined that these
 characteristics impact toxicity, and enough data exist to
 establish the relationship.  Table 1 lists the chemicals for
 which freshwater aquatic life criteria have been developed and
 indicates which of those criteria are pH, hardness, or
 temperature dependent.


 SITE-SPECIFIC GUIDELINES

     An option for modifying national aquatic life water quality
 criteria to reflect local conditions is presented in the site-
 specific guidelines.  States may develop site-specific criteria
 by modifying the national criteria for sites where 1) water
 quality characteristics, such as pH, hardness, temperature, etc.,
 that might impact toxicity of the pollutants of concern differ
 from the laboratory water used in developing the criterion; or 2)
 the types of organisms at the site differ from, and may be more
 or less sensitive than, those used to calculate the criterion; or
 3) both may be true,  site-specific criteria take local
 conditions into account to provide an appropriate level of
 protection.  They can also be used to set seasonal criteria when
 there is high temporal variability.6

     A testing program can be used to determine whether site-
 specific modifications to criteria are necessary.  This program
 may include water quality sampling and analysis, a biological
 survey,  and acute and chronic toxicity tests.11  If site-specific
 modifications are deemed necessary,  3 separate procedures are
 available for using site-specific guidelines to modify criteria
 values,  including the recalculation procedure, the indicator
 species procedure,  and the resident species procedure.  These
will be discussed more fully in the next section.
                                8

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                             SECTION  3

      THE NEED FOR EVALUATING NUMERIC WATER QUALITY CRITERIA:
                USE OF THE SITE-SPECIFIC GUIDELINES


 OVERALL RELEVANCE OF CRITERIA TO WETLANDS

      The national aquatic life criteria have been developed to
 provide guidance  to the  States for the protection of aquatic life
 and  their uses in a variety  of surface waters.  They are designed
 to be conservative and "...  have been developed on the theory
 that effects  which occur on  a species in appropriate laboratory
 tests will generally occur on the same species in comparable
 field situations.   All North American bodies of water and
 resident aquatic  species and their uses are meant to be taken
 into account,  except for a few that  may be too atypical ..,"9  A
 wide variety  of taxonomic groups sensitive to many materials are
 used in testing,  including many taxa common to both wetlands and
 other surface waters.  In order to ensure that criteria are
 appropriately protective,  water used for testing is low in
 particulate matter and organic matter, because these substances
 can  reduce availability  and  toxicity of some chemicals.  For
 these reasons,  the "National Guidance: Water Quality Standards
 for  Wetlands"  states that, in most cases, criteria should be
 protective of  wetland biota.6

      Although  the water  quality criteria are probably generally
protective of  wetlands and provide the best currently available
 tool  for regulating contamination from specific pollutants, there
 are many different types of  wetlands with widely variable
conditions.  There might be  some wetland types where the resident
biota or chemical  and physical conditions are substantially
different from what the  criteria were designed to protect.  These
differences could result in  underprotection or overprotection of
the wetland resource.  This  section  discusses the use of site-
specific guidelines for  wetland types for which certain criteria
might be over  or  underprotective, but its primary focus is to
provide  a mechanism to identify wetland types that might be
underprotected by certain criteria and that might require further
research.

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WETLAND VARIABILITY


     Wetlands are usually located at the interface between
terrestrial systems and truly aquatic systems, and so combine
attributes of both.12  They are intermediate between terrestrial
and aquatic systems in the amount of water they store and process
and are very sensitive to changes in hydrology.12  Their chemical
and physical properties, such as nutrient availability, degree of
substrate anoxia, soil salinity, sediment properties, and pH are
influenced greatly by hydrologic conditions.  Attendees at a
Wetlands Water Quality Workshop (held in Easton,  Maryland in
August, 1988) listed the most common ways in which wetlands
differ from "typical" surface waters:_  higher concentrations of
organic carbon and particulate matter, more variable and
generally lower pH, more variable and generally lower dissolved
oxygen, more variable temperatures, and more transient
availability of water.13

     There is also high variability among wetland types.
Wetlands, by definition, share hydrophytic vegetation, hydric
soils, and a water table at or near the surface at some time
during the growing season.  Beyond these shared features,
however, there is tremendous hydrological, physical, chemical,
and biological variability.   For example, an early
classification system for wetlands. "Circular 39", listed 20
distinctly different wetland types , and the present  "Cowardin"
system lists 56 classes of wetlands.15  This variability makes  it
important to evaluate different wetland types individually.


USE OF THE SITE-SPECIFIC GUIDELINES FOR WETLANDS

     The site-specific guidelines outlined in Section 2 are
designed to address the chemical and biological variability
described above.  Determining the need for site-specific
modifications to criteria requires a comparison of the aquatic
biota and chemical conditions at the site to those used for
establishing the criterion.  This comparison is useful for
identifying wetland types that might require additional
evaluation.  The three site-specific options are discussed in the
context of their general relevance to wetlands and are used in
this discussion to provide a framework for evaluating the
protectiveness of criteria for wetlands.

     In most cases, because of the conservative approach used  in
the derivation of the criteria, use of the site-specific
guidelines to modify criteria results in no change or fin their
relaxation, provided that an adequate number of species are used
in the calculations.  However, criteria can also become more


                                10

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 restrictive.  Newly tested species could be especially sensitive
 to certain pollutants, or extreme water conditions found in some
 surface waters or wetland types might not reduce the toxicity of
 a chemical.  Disease, parasites,  predators, other pollutants,
 contaminated or insufficient food,  and fluctuating and extreme
 conditions might all affect the ability of organisms to withstand
 toxic pollutants.9

 Appropriateness of Testing Organisms •   Recalculation Procedure

      The first option given in the  site-specific guidelines is
 the recalculation procedure.8-11  This approach is designed to
 take into account differences between the sensitivity of resident
 species and those used to calculate a criterion for the material
 of concern.  It involves eliminating data from the criterion
 database for species that are not resident at that site.   It
 could require additional resident species testing in laboratory
 waiter if the number of species remaining for recalculating the
 criterion drops below the minimum data requirements.   "Resident"
 species include those that seasonally or intermittently exist at
     Use  of  the  recalculation  procedure will  not necessarily
 result  in a  higher acute criterion value  (less  restrictive) ,  even
 it sensitive species  are eliminated  from  the  dataset  and minimum
 family  requirements are met.   The number  of families  used  to
 calculate Final  Acute Values is important.  If  a number of non-
 t?«tland species  are dropped out of the calculation  without adding
 a sufficient number of new species,  a lower (more restrictive)
 Final Acute  Value  can result,  because data are  available for
      species.11
Similarity of Required  Taxa and Typical Wetland Species —
     The variety of  test  species required to establish the
national numeric criteria was chosen to represent a wide range of
tasea having a wide range  of habitat requirements and sensitivity
to toxicants.  Establishment of a freshwater Final Acute Value
for a chemical requires a minimum of 8 different types of
families to be tested.  These include:  1) the family Salmonidae;
2) a second family of fish, preferably a warmwater species;  3) a
third family in the  phylum Chordata (fish, amphibian, etc.); 4) a
planktonic crustacean;  5) a benthic crustacean; 6) an insect; 7)
a family in a phylum other than Arthropoda or Chordata; and  8) a
family in any order  of  insect or phylum not already represented.9

     When a required type of family does not exist at a site, the
guidelines for the recalculation procedure specify that
substitutes from a sensitive family, resident in the site, should
be added to meet the minimum family data requirement.  Should it
happen that all resident  families have been tested and the


                                11

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 minimum data  requirements still have not been met,  the acute
 toxicity value  from the most sensitive resident  family that has
 been tested should be used as the site-specific  value.

      Most of  the  required families are probably  well-represented
 in most wetland types.   Some types of wetlands,  however, seldom
 or never contain  fish,  and most wetland types do not support
 salmonids or  aquatic insects requiring flowing water.

 General Evaluation of Species Suitability—
      Table 2  presents six criterion chemicals chosen as examples
 and the eight taxonomic groups required to establish criteria.
 The chemicals include two organochlorines:  polychlorinated
 biphenyls (PCBs -  used in industrial applications,
 environmentally-persistent,  bioaccumulate) and pentachlorophenol
 (widely used  fungicide and bactericide); one organophosphate:
 parathion (insecticide);  two metals:  zinc and chromium(VI); and
 cyanide.

      The  species used for acute toxicity testing for each of the
 six chemicals have been broken down by taxonomic group and
 evaluated based on the  likelihood that those species can be found
 in  wetlands.  Except  for the unsuitability of the Salmonidae to
 most wetland  types, most of  the taxonomic groups are well-
 represented for the six chemicals used as examples.  Wetland
 species were  not present  in  the list of species used to calculate
 the Final  Acute Value  for the "non-arthropod/non-chordate" and
 "another  insect or new  phylum" groups for a few  of the criteria.
 This  is not because these groups are not represented in wetlands.
 These are  very general  classifications.  For example, the "non-
 arthropod/non-chordate" group can include rotifers, annelids, and
 mollusks among other phyla,  all of which should have many
 representatives in most types of wetlands.  There is a large
 degree of  variation in the total number of species tested for the
 six chemicals used as examples, ranging from 10  fish and
 invertebrates for polychlorinated biphenyls (PCBs) to 45 for zinc
 (Table 7).  Criteria based on smaller numbers of species are less
 likely to  include a sufficient number of wetland species to
 fulfill the minimum family requirements.   Additional toxicity
 testing, using laboratory water and wetland species from the
 missing families,  can be  done to fill these gaps.

     While the general taxonomic groups required for toxicity
 testing are fairly well represented in wetlands, the similarity
 between the genera and species inhabiting individual wetland
types and those used for criteria testing varies widely among
 criteria and wetland types.  Species chosen for toxicity testing
were seldom or never chosen with wetlands in mind.  Intaddition,
 relatively little is known about species assemblages in some
types of wetlands  (particularly in those lacking surface waters,


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 such as wet meadows or bogs).  Defining typical wetland taxa is
 difficult.   For example, while most £xfifiS of wetlands do not
 support salmonids,  Coho salmon are highly dependent on wetlands
 in Alaska,  where there is a  higher percentage and acreage of
 wetlands than  in any other State.  Part of the utility of the
 evaluation  proposed here is  in identifying where significant gaps
 in data exist.

 Influence of Cofactors:  Indicator Species Procedure

      The second of  the three site-specific procedures, the
 indicator species procedure, accounts for differences in
 biological  availability and/or toxicity of a material caused by
 physical and/or chemical characteristics of the site water, or
 cofactors.   For the acute test, the effect of site water is
 compared to the effect of laboratory water, using at least two
 resident species or acceptable non-resident species (one fish and
 one invertebrate) as indicators.  A ratio is determined, which is
 used to modify  the  Final Acute Value.  See Carlson et al. (1984)
 for information and guidelines for determination of site-specific
 chronic values.11

 Suitability of  Standard Testing Conditions—
      Standard aquatic  toxicity tests are performed using natural
 or reconstituted dilution water that should not of itself affect
 the  results of  toxicity tests.  For example, organic carbon and
 particulate matter  are required to be low to avoid sorption or
 complexation of  toxicants, which might lower the toxicity or
 availability of  some criterion chemicals.  Recommended acute test
 conditions  for  certain water quality characteristics of fresh and
 salt  water  are  listed  in Table 3.  Wetlands, as well as some
 types of  surface waters, can have values far outside the ranges
 used  for  standard testing for some of these characteristics (most
 notably total organic  carbon, particulate matter, pH, and
dissolved oxygen).  Wetland types can be evaluated to identify
these extremes.

Wetland Cofactors—
     Many water  quality characteristics can 1) act as cof actors
 to affect the toxicity of pollutants (e.g.  alkalinity/acidity,
hardness, ionic  strength, organic matter, temperature, dissolved
oxygen, suspended solids); 2) can be directly toxic to organisms
 (e.g. un-ionized ammonia, high or low pH, hydrogen sulfide, low
dissolved oxygen); or  3) can interfere mechanically with feeding
and reproduction  (e.g. suspended solids). The criteria for some
of these  water quality characteristics can be naturally exceeded
in many wetland types, as well as in some lakes and streams.

     Hardness,  pH, and temperature adjustments built into a few
of the criteria account for effects from these cof actors in a few


                               13

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 cases, but no other cofactors are now included in the criteria,
 despite some known effects.  For example, alkalinity, salinity,
 and  suspended solids, in addition to pH and hardness, are known
 to affect the toxicities of heavy metals and ammonia.  These
 cofactors are not included in the criteria primarily because
 there are insufficient data.9  For example,  most toxicity tests
 have been performed under conditions of low or high salinity, so
 that estuaries, where salinity values can vary greatly, may
 require salinity-dependent site-specific criteria for some
 metals.11  An initial evaluation of the adequacy of protection
 provided to a wetland type by a criterion should take possible
 cofactor effects into account.

 t^oph iiiation i  Resident Species Procedure

     The resident species procedure accounts for differences in
 both species sensitivity and water quality characteristics.11
 This procedure is costly, because it requires that a complete
 minimum dataset be developed using site water and resident
 species.  It is designed to compensate concurrently for
 differences in the sensitivity range of species represented in
 the  dataset used to derive the criterion and for site water
 differences which may markedly affect the biological availability
 and/or toxicity of the chemical.11


 AQUATIC PLANTS

     One of the most notable differences between wetlands and
 other types of surface waters is the dominance (and importance)
 of aquatic macrophytes and other hydrophytic vegetation in
 wetlands.   Aquatic plants probably constitute the majority of the
 biomass in most wetland types.

     Few data concerning toxicity to aquatic plants are currently
 required for deriving aquatic life criteria.  Traditionally,
 procedures for aquatic toxicity tests on plants have not been as
 well developed as for animals.  Although national numeric
 criteria development guidelines state that results of a test with
 a freshwater alga or vascular plant "should be available" for
 establishing a criterion, they do not require that information.9
The Final  Plant Value is the lowest (most sensitive) result from
 tests with important aquatic plant species (vascular plant or
 alga),  in which the concentrations of test material were measured
 and the endpoint was biologically important.  Plant values are
compared to animal values to determine the relative sensitivities
of aquatic plants and animals.  If plants are "among the aquatic
organisms  that are most sensitive to the material," results of a
second test with a plant from another phylum are included.9
                                14

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     Results of tests with plants usually indicate that criteria
which protect aquatic animals and their uses also protect aquatic
plants and their uses.9  As criteria are evaluated for their
suitability for wetlands, however, plant values should be
examined carefully.  Additional plant testing may be advisable in
some cases.  If site-specific adjustments are made to some
criteria, they could result in less restrictive acute and chronic
values for animals.  Some plant values could then be as sensitive
or more sensitive than the animal values.  Chemicals with fairly
sensitive plant values include:  aluminum, arsenic(III), cadmium,
chloride, chromium(VI}, cyanide, and selenium(VI).  For example,
fish are generally much more sensitive to cyanide than
invertebrates.  If the recalculation procedure was used to
develop a site-specific cyanide criterion for a wetland type
containing no fish, values for these ''sensitive species would be
replaced in the calculation, possibly by less sensitive species.
A less restrictive criterion could result, possibly making the
plant value more sensitive than the animal value.  Therefore,
additional consideration should be given to plant toxicity data
for wetland systems.
                                15

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                            SECTION 4

                        EVALUATION PROGRAM


     The direct application of existing aquatic life criteria to
wetlands is assumed to be reasonable in most cases.  It provides
a practical approach towards protecting the biological integrity
of wetlands.  The following evaluation program offers a possible
strategy to identify extreme wetland -'types that might be
underprotected by some criteria, to prioritize wetland types and
criterion chemicals for further testing or research, and to
identify gaps in available data.  The approach can be helpful for
identifying those instances where modifications to existing
criteria might be advisable.  The proposed evaluation program
offers a screening tool to begin to answer the following
questions:  1) Are there some wetland types for which certain
criteria are underprotective?  2) For criteria in wetland types
that cannot be applied directly, can site-specific guidelines be
used to modify the criteria to protect the wetland?  3) Will
additional toxicity testing under wetland conditions and with
wetland species be necessary in some cases in order to establish
site-specific criteria?

     The proposed approach relates species and water quality
characteristics of individual wetland types to species and water
quality characteristics important in deriving each criterion.  It
involves identifying wetland types of concern, identifying
cofactors possibly affecting toxicity for the criteria of
interest, gathering data on the biota and water quality
characteristics of the wetland type, and comparing to data used
to derive the criterion*
CLASSIFICATION

     The proposed program for the evaluation of the suitability
of aquatic life criteria discussed in this section can be done
separately for individual wetland types.  These can be defined in
the classification process, which is the first step in developing
standards for wetlands.  The classification process requires the
identification of the various structural types of wetlands and
identification of their functions and values.*  The
classification should provide groups of wetlands that are similar
                                16

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 enough structurally and functionally so  that they can  reasonably
 be expected to respond in kind to inputs of toxic chemicals.


 EVALUATING THE APPROPRIATENESS OF DIRECT APPLICATION OF CRITERIA

 Information Needed

      1.   Identification of cofactors.  Cofactors potentially
 affecting mobility and biological availability for each criterion
 chemical  should be identified.  Cofactors known to affect each
 criterion chemical are listed  in  individual national criteria
 documents and  are  summarized in Table 4.  The absence  of a
 relationship between.a cofactor and  a chemical on Table 4 does
 not ensure that no relationship exists, merely that none was
 discussed in the criteria document.  The  chemistry of  the effects
 of the cofactors on the chemicals is often very complicated, and
 limited data are available regarding some of the relationships.
 The approach presented here is  simplistic and is geared toward
 directing further  efforts,  other sources of information, in
 addition  to the criteria documents,  should be consulted when
 actually  applying  this approach.   Criteria that include hardness-
 or pH-dependent correction factors (Table 1) should apply
 directly  to wetlands unless the wetland type has extremes of pH
 or hardness well outside the ranges  used  in toxicity testing.
 For example, the pH of acid bogs  can be as low as 3.5, well below
 the 6.5 lower  limit for toxicity  testing  (Table 3).

     2.   Comparison to wetland  water chemistry*  Natural levels
 and variability of those cofactors should be identified as well
 as  possible for each major wetland type of interest.  Wetlands*
 related information can be accumulated through consultation with
 wetland researchers, through literature searches, and  from
 monitoring  agencies.

     3.   Comparison of species  lists.  Species lists of fish,
 invertebrates,  and plants should  be  compiled for each wetland
 type and  compared  to lists of species used for testing each
 criterion.   Lists  should be evaluated on  two levels:  a) Species
 level - Are  the species  used for  toxicity testing representative
 (the same species  or genera, or "similar" in terms of sensitivity
 to toxicants) of the species found in the wetland type?
b)  Family level -  Does  the wetland contain suitable
 representatives for each of the families  listed in the minimum
 family requirements?8'11  Consultation with fish and  invertebrate
 specialists, plant  ecologists, and wetlands experts will be
necessary to do this comparison.
                                17

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Adoption of ExisiHprf water Quality
     The existing water quality criterion should be suitable for
 that wetland type if the following are true:

     1.  Important cof actor levels are not naturally exceeded in
 the wetland to a degree that might seriously affect toxicity or
 availability of the chemical.  Would toxicity likely be higher,
 lower, or not influenced by typical levels or extremes of a
 particular cof actor in a particular wetland type?

     2.  Sufficient species or genera used for aquatic toxicity
 testing are found in the wetland type so that the minimum family
 requirements can be met by resident wetland species.
 Consultation between wetland scientists and criteria experts will
 be necessary in many cases to make judgements on how well-
 represented some wetland types are.

     3.  The criterion itself is not naturally exceeded in the
 wetland.
DEVELOPING SITE-SPECIFIC CRITERIA

     When one or more of these stipulations is not true or when
insufficient data are available, more evaluation is advisable.
Again, consultation between wetland scientists and criteria
experts might be helpful in prioritizing those wetland types for
which additional protection, or additional research, might be
needed for some chemicals.  Once a priority list for further
evaluation is established, an approach to obtaining the
additional required data can be determined.  It might be possible
to group wetlands by type, and possibly by designated use, and
then develop site-specific criteria for all wetlands of that type
in the State.
                                18

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                             SECTION 5

                         EXAMPLE ANALYSES


      Evaluations  of the  applicability of the six criteria listed
 in Table  2 will be made  for  two sets of wetland data, including
 shallow marshes and prairie  potholes.  The analyses in these
 examples  were made with  limited data for each wetland type and
 are preliminary.   They have  been compiled to be used only as
 illustrations of  the usefulness of this approach.


 EXAMPLE 1

      The  first example is based on a wetland study taking place
 in southcentral Minnesota.   The wetlands are being studied to
 evaluate  the effects of  disturbance on water quality, as well as
 the effects of pesticides on wetland communities.  Therefore
 chemical  and biological  data have been collected.18

 Classification

      The  wetland  study sites are primarily shallow marshes
 (freshwater palustrine,  persistent emergent, semi-permanently or
 seasonally-flooded,  according to Co war din15), dominated by
 Phalaris  (reed canary grass) and Typha (cattails), but also
 include a small number of wet meadow/seasonally-flooded wetlands,
 deep marsh, shrub/scrub  + woody wetlands, and ponds.

 steps 1 and 2:  Identification of Cofactors and Comparison to
 Wetland Water Chemistry

     Cofactors are  identified for criteria chemicals in Table 4.
 Some water quality  characteristics averaged for 5 seasons for the
Minnesota wetlands  are summarized in Table 5.

     Although some  water chemistry conditions in the shallow
marshes were within the  ranges of the aquatic toxicity testing
conditions, others  were  exceeded (Table 3).  Wetland values for
pH were well within the  6.5-9.0 range allowed for testing, so
criteria having pH  as  a  possible cofactor affecting toxicity
and/or biological availability should not be underprotective
because of pH effects.   As Table 4 shows, PCP, chromium(VI),
zinc,  and cyanide can  be more toxic at low pH values, so a very


                                19

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 acidic wetland  might require  additional evaluation  in regard to
 pH.   The PCP  criterion has an adjustment factor  for pH, which
 indicates that  enough suitable data are available to allow this
 relationship  to be  incorporated  into the criterion.

      Hardness values were not available for these marshes, but
 were  probably fairly low since alkalinity was low.  Table 4 lists
 hardness as a cofactor for zinc  and chromium(VI).   Table 1
 reveals that  the  zinc criterion  has an adjustment factor for
 hardness,  so  any  effect of hardness on zinc toxicity and/or
 biological availability is already included in the  criterion and
 does  not have to  be considered further.  Chromium(VI) is more
 toxic at low  alkalinity and hardness, but the criterion was
 derived using soft  water and  should he protective for the
 wetlands.

      Total organic  carbon (TOG)  was highly variable in the
 wetlands and  generally well above the 5 mg/L limit  for toxicity
 testing.   However parathion and  zinc, the two criteria with TOG
 cofactor effects, have reduced toxicity and/or biological
 availability  at high levels of organit matter (Table 4), so
 criteria should be  protective.

      Dissolved oxygen (DO) was highly variable in the wetlands
 and reached very  low levels in late summer.  The shallow waters
 of the marshes were  extremely warm on hot summer days.  Toxicity
 and/or biological availability is increased by low  DO and high
 temperatures  for  PCBs,  PCP,  and  cyanide.  These relationships
 will  require  further evaluation.

 Step  3:  Comparisons  of Species  Lists

      In  Step  3,  fish,  invertebrates, and plants inhabiting the
wetlands are compared  to species used in testing each criterion.
 For these examples, only the acute toxicity lists have been
 consulted.  A list of  genera common to both the marshes and to
 the toxicity tests was  compiled  for each criterion.  When
 identical species were  not found, species from the  same genus
were compared to determine whether habitat requirements are
 suitable enough to include them  as representative species for
these wetlands.   The shortened list of marsh species the same as,
or similar to, species used for toxicity testing was examined to
determine whether the minimum family requirements for acute
toxicity tests could be met for each criterion.  Table 6 contains
a list of marsh genera that could be used to fulfill minimum
family requirements for each criterion.  Appendix A contains a
list of the sources that have been consulted in making this
comparison.
                                20

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     The aquatic species found in the Minnesota wetlands were
fairly veil-represented by the acute toxicity test species for
the six chemicals used in this example.  The percentages of total
species tested that have not been found in these wetlands were
below 50% for all six criteria (Table 7).  Except for PCBs, for
which no plant value is available, plant species tested
overlapped with species occurring in the wetlands.  The absence
of salmonids in wetlands was the only consistent omission.

     Of all the species tested, the salmonids are the most
sensitive to PCP and cyanide and are much more sensitive than
most invertebrate species.  The inclusion of highly sensitive
salmonid data in the criteria calculations probably ensures that
these two criteria' are adequately protective when applied to
wetlands not containing this sensitive family (not considering
cofactor effects).  It would perhaps be more important to
consider the effects of the absence of salmonids in Minnesota
marshes for criteria where salmonids are among the least
sensitive species, including parathion and chromium(VI).  In this
case, the presence of salmonid toxicity data in the criterion
calculation, despite their absence from the wetlands, could
possibly cause the criterion to be less restrictive than is
appropriate for the wetland.

     Salmonids do not occur in the wetlands included in this
example.  Three criteria were missing an additional required
taxonomic group (from Table 6:  PCBs, chromium(VI), and cyanide).
There are certainly representatives of this taxonomic group
(nonarthropod/nonchordate) inhabiting the wetlands, but the
genera used for toxicity tests did not correspond to the wetland
genera.  These three criteria have the least species on the acute
toxicity list,  so there are less species to compare to, in
relation to the other criteria (Table 7).   Toxicity experts and
wetland biologists might be able to fill some of these data gaps
by reaching conclusions on the suitability of wetland species to
fulfill the minimum family requirements.


EXAMPLE 2

     This example is based on data for a number of oligosaline
prairie pothole wetlands in southcentral North Dakota. w'w
Oligosaline is defined as ranging from 0.5-5 g/Jcg salinity, or
specific conductance of 800-8,000 nS/cm at 25°C."
The chemical types of the majority of wetlands used in this
example include magnesium bicarbonate, magnesium sulfate, and
sodium sulfate.20
                               21

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 classification

     wetlands included in this example are semipermanent  (cover
 type 4 of the classification system developed by Stewart and
 Kantrud  for the glaciated prairie region)2f, containing wet
 meadow,  shallow marsh, and deep marsh.  Classification of these
 wetlands based on the Cowardin system can be found in Kantrud et
 al.20

 Steps 1  and 2:  Identification of Cofactors and Comparison to
 Wetland  Water Chemistry

     Cofactors are identified for criteria chemicals in Table 4.
 Water quality data for the prairie pfethole wetlands are
 summarized in Table 8.  A comparison of water chemistry
 conditions for the prairie potholes with standard toxicological
 testing  conditions (Table 3) reveals a number of differences.

     These wetlands are extremely alkaline and saline compared to
 water used for freshwater toxicity testing.  Salinity (reported
 as specific conductance) can vary greatly over the year and is
 concentrated by the high rates of evaporation and transpiration
 that take place in the summer.  A number of the wetlands have pH
 values above the 6.5-9.0 range that the criteria are designed to
 protect.  No data were available for total organic carbon (TOC),
 but dissolved organic carbon values from other prairie pothole
 systems  were generally well above the TOC limit of 5 mg/L used
 for toxicity testing.22  As in Example 1, hardness can be
 eliminated from consideration as a cofactor, because toxicity
 and/or biological availability is decreased as hardness
 increases.  Similarly, the probable high TOC levels would
 decrease toxicity and/or biological availability for zinc and
 chromium(VI).   The high pH values should cause decreased toxicity
 and/or biological availability.  Bioavailability of zinc is
 reduced  in high ionic strength waters such as these.

     Dissolved oxygen (DO)  levels drop in the winter and in
middle to late summer, allowing anoxic conditions to develop.
Although no aquatic temperature data were available, the Dakotas
have moderately hot summers (mean July temperature of 22.3°C).20
The shallow waters of the prairie potholes probably become very
warm in late summer,  corresponding with low DO levels.  Toxicity
and/or biological availability is increased by low DO and high
temperatures for PCBs, PCP, and cyanide.  These relationships
will require further evaluation.

step 3;   Comparisons of Species Lists
 -  -  -- 	   •-        ••	  •-                             f.

     Semi-permanent prairie pothole wetlands are generally
shallow and eutrophic.  Water levels fluctuate greatly, as does


                                22

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 salinity.   The cold winters can cause some of the wetlands to
 freeze  to  the bottom.   Both winter-Kill and summerkill, caused by
 the  effects of lack of oxygen, can occur.  Fish can survive only
 in semipermanent wetlands  that have connections to deeper water
 habitat.   The only native  fishes known to occur in semi-permanent
 prairie potholes are fathead minnow fPimenhales prone 1 as i and
 brook stickleback fCulaea
     The  invertebrate taxa of prairie potholes are typical of
other eutrophic,  alkaline systems in the United States.
Macroinvertebrate species assemblages are highly influenced by
hydroperiod  and salinity in these systems, and species diversity
drops as  salinity increases.20  Care must be taken in aggregating
large salinity ranges into one wetland type (i.e. "oligosaline"
may ba too broad  a class in terms of species representativeness) .
Comparisons  of species typical of the wetlands with the criteria
species lists reveals some major differences.  For example, a
large proportion  of the aquatic insects tested for each criterion
are found in flowing water, and therefore might not be
characteristic of prairie pothole aquatic inspects.  Although many
species of aquatic insects are found. in these* wetlands20, there
are not many suitable aquatic insects on the criteria species
lists to  compare  to resident wetland species.  Prairie pothole
wetlands  do  not harbor Decapods (crayfish and shrimp) , another
common group for  testing.  Eubranchiopods (fairy, tadpole, and
clam shrimp) are  commonly found in prairie pothole wetlands20,
but only  one representative of this group has been used to
establish criteria,  and that species was not on the list for any
of the criteria used as examples here.  Except for PCBs, for
which no  plant value is available, plant species tested do
overlap with species occurring in the wetlands.  Appendix B
contains  sources  used in making comparisons.

     The  above discussion has obvious implications for
determining  applicability of criteria based on suitability of
species.  As Table 7 shows, the percentages of species tested for
each criterion that have not been found in prairie potholes are
rather high  (up to 67%) .  There are more gaps in the minimum
family requirements for fish and chordates (Table 9) than were
found for the Minnesota marsh example.  The lack of fish in these
wetlands  dictates that amphibians or other chordates be used to
fill these family requirements.  The paucity of fish in these
wetlands  again has relevance to the protectiveness of the
criteria.  Fish are the most sensitive group tested for PCP and
cyanide,  so  these criteria may have an added "buffer" of
protection (in relation to the other criteria used as examples)
when applied with no modifications to this wetland type.
                                23

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SUMMARY OF THE EXAMPLE ANALYSES

     The conclusions discussed below should be considered as
examples only.  They should not be considered final for these
wetland types.

Cofactor Effects

     Based on this simple analysis, the only cofactors that
potentially could cause criteria to be underprotective were DO
and temperature.  The low DO and high temperatures common in both
wetland types in mid to late summer could cause increased
toxicity and/or biological availability for PCBs, PCP, and
cyanide.  Cofactor effects for chromium(VI}, zinc, and parathion
were either not important under the chemical conditions
encountered in these wetlands or should result in criteria being
more, rather than less, protective for the wetland biota.  Based
on water quality characteristics, it can be concluded that
chromium(VI), zinc, and parathion criteria are probably
adequately protective of these wetland types with no acute
modification.

     The importance of the DO and temperature relationship
requires further evaluation for PCBs, PCP, and cyanide.  Chemists
and wetlands experts should be consulted and further literature
reviews should be completed to evaluate the need for additional
toxicity tests.  If it is determined that a modification to a
criterion is warranted, seasonal site-specific criteria might be
appropriate in this case.  The indicator species procedure could
be used, requiring toxicity tests using site water on one fish
and one invertebrate.  The tests could be done at the high
temperatures and low DO found in late summer in the wetlands.

Species Comparisons

     The Salmonidae are a required family group for establishing
a Final Acute Value and yet are not present in either of the
wetland types used as examples.  This evaluation is most
concerned with ensuring that criteria are adequately protective,
so the absence of this family in the wetlands should only be
considered a problem if the unmodified criterion  (which includes
the Salmonidae) might be underprotective.  This would most likely
be true for parathion and chromium(VI).

     For several criteria, some family requirements are not
fulfilled because the available toxicity data for that taxonomic
group do not include wetland species or genera ("NT" in Tables 6
and 9).  While this document made comparisons at the genus level,
others have made comparisons at the family level to determine if
the species listed in the criteria document is a member of a


                                24

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 family that exists at  the  site.16  Issues  related  to  species
 comparisons should be  addressed  through discussion with criteria
 experts and wetlands ecologists  and through further  literature
 review.

     The absence of fish in prairie potholes to fill the "other
 chordates11 category for cyanide, zinc, chromium(VI), and PCBs may
 warrant additional toxicity tests and site-specific
 modifications.  The only other fish likely to be present in these
 wetlands is the brook  stickleback  (Culaea inconstansl20 which was
 not tested for any of  the  six criteria.  No non-fish chordates
 were tested either, so no  evaluation of the probable sensitivity
 of other chordates to  these criteria can be made based on the
 criteria documents^

     If it is decided  upon more  rigorous evaluation that these
 differences in taxonomic groups  warrant additional efforts and
 development of site-specific criteria, the recalculation
 procedure can be used.  A  suitable family, resident in the
 wetlands, can be added to  the list to replace the Salmonidae
 and/or other missing groups, either through additional toxicity
 tests or by including  additional available data.

 Further Evaluation

     This approach helps to prioritize wetland types and criteria
 for further evaluation.  It was  concluded that zinc,
 chromium(VI), and parathion criteria require no modification with
 regard to cofactor effects.  PCBs, PCP, and cyanide, however,
 should be evaluated further in regard to the effects of high
 temperatures and low DO on toxicity, for both wetland types.  The
 absence of salmonids may be most important for parathion and
 chromium(VI) in both wetland types.  Further consideration should
be given to the need for additional tests with chordates from
prairie pothole wetlands for cyanide, zinc, chromium(VI) and
 PCBs, although there is no evidence to suggest that the absence
of representative wetland  chordates from the test species will
 result in underprotective  criteria.

     This type of evaluation, done for a number of wetland types
and criteria, can be combined with information on the types of
pollutants that threaten particular wetland types.  In this way
wetland types requiring additional evaluation and perhaps
eventually some additional toxicity testing for particular
pollutants can be prioritized based on adequacy of existing
criteria, potential threats to the system, and resources
available for testing.  These examples illustrate the need for
wetland scientists to  work closely with criteria experts.  Expert
 judgement is needed to evaluate  the significance of the gaps in
the available data.


                                25

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                            SECTION 6

                           CONCLUSIONS


     The  efficient use of limited resources dictates that
 criteria  and standards for wetlands be developed by making good
 use of the wealth of data that has been accumulated for other
 surface waters.  This report focused ,on the application of
 numeric aquatic life criteria to wetlands.  The numeric aquatic
 life criteria are designed to protect aquatic life and their
 uses.  The criteria are conservative,  and for most wetland types
 are probably protective or overprotective.

     A simple, inexpensive evaluation technique has been proposed
 in this document for detecting wetland types that might be
 underprotected for some chemicals by existing criteria.  The
 approach  relies on information contained in criteria documents,
 data regarding species composition and water quality
 characteristics for the wetland types of interest, and
 consultation with experts.  It is intended to be used as a
 screening tool for prioritizing those wetland types that require
 additional evaluations and research.

     Two  tests of the approach demonstrated that it can be used
 to identify cases in which criteria might be underprotective, but
 further evaluation and close coordination among regulatory
 agencies, wetland scientists,  and criteria experts are needed to
 determine when actual modifications to the criteria are
 necessary.

     Site-specific guidelines for modifying the numeric criteria
 should be appropriate for use on wetlands in cases where
 additional evaluations reveal that modifications are needed.  The
 approach described in this document can be used to compile lists
 of the most commonly under-represented species and the most
 frequently encountered chemicals.  Aquatic toxicity tests can
then be conducted which would apply to a number of wetland types.

     Information obtained with this approach can be used to
prioritize further evaluations and research, identify gaps in
data,  and make further testing more efficient, but has some
limitations.   It does not adequately address the importance of
plants in wetland systems and applies only to the aquatic
component of wetlands.   It relies on species assemblage and water


                               26

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quality data that are not available for some wetland types.  For
these reasons, a meeting of wetland scientists and criteria
experts is recommended to discuss the need for this type of
evaluation, the utility of this approach, and possible
alternative approaches.

     The application of numeric criteria to wetlands is just one
part of a large effort to develop wetland standards and criteria.
The development of biocriteria, sediment criteria, and wildlife
criteria will help to ensure that all components of the wetland
resource are adequately protected.
                               27

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                            REFERENCES


 1.   U.S. Fish and Wildlife Service.  1984.  An Overview of Major
     Wetland Functions and Values.

 2.   Tiner, R.W., Jr.  1984.  Wetlands of the United States:
     Current Status and Recent Trends.   U.S. Fish and Wildlife
     Service.       •                .

 3.   U.S. EPA, Office of Water.  1989.   The Water Planet.

 4.   The Conservation Foundation.  1988.  Protecting America's
     Wetlands:  An Action Agenda:  The Final Report of the
     National Wetlands Policy Forum.

 5.   U.S. EPA, Office of Water Regulations and Standards, Office
     of Wetlands Protection.  1989.  Survey of State Water
     Quality Standards for Wetlands.  Internal report.

 6.   U.S. EPA, Office of Water Regulations and Standards, Office
     of Wetlands Protection.  In Review.  Draft National
     Guidance:  Water Quality Standards for Wetlands.

 7.   Adamiis, P.R., K. Brandt, and M. Brown.  1990.  Use of
     Biological Community Measurements for Determining Ecological
     Condition of, and Criteria for, Inland Wetlands of the
     United States - A Survey of Techniques, Indicators,
     Locations, and Applications.  U.S.  EPA, Corvallis, Oregon.

8.   U.S. EPA, Office of Water Regulations and Standards.  1986.
     Quality Criteria for Water.   EPA-440/5-86-001.  U.S. EPA,
     Washington,  D.C.

9.   Stephan,  C.E., D.I.  Mount, D.J. Hansen, J.H. Gentile, G.A.
     Chapman,  and W.A. Brungs.  1985.   Guidelines for Deriving
     Numerical National Water Quality Criteria for the Protection
     of Aquatic Organisms and Their Uses.  PB85-227049.  National
     Technical Information Service, Springfield, Virginia.

10.   U.S. EPA, Office of Water.  1985.   Technical Support
     Document for Water Quality-based Toxics Control.  EPA-440/4-
     85-032.
                               28

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 11.   Carlson, A.R.,  W.A.  Brungs, G.A.  Chapman,  and D.J.  Hansen.
      1984.   Guidelines for Deriving Numerical Aquatic Site-
      Specific Water  Quality criteria by Modifying National
      Criteria.   EPA-600/3-84-099.  U.S. EPA, Duluth,  Minnesota.

 12.   Mitsch, W.J.  and J.G.  GosselinJc.  1986.  Wetlands.   New
      York:   Van  Nostrand  Reinhold.

 13.   Phillip, K.   1989.   Review of Regulated Substances  and
      Potential Cofactors  in Wetland Environments.   Draft internal
      report  submitted to  U.S. EPA.

 14.   Shaw, S.P., and C.G.  Fredine.  1956.  Wetlands of the United
      States, Their- Extent,  and Their Value for  Waterfowl and
      Other Wildlife.   U.S.  Fish and* Wildlife Service,  Circular
      39.  Washington,  D.C.,  67p.

 15.   Cowardin, L.M.,  V. Carter, F.C. Golet, and E.T.  LaRoe.
      1979.   Classification  of Wetlands and Deepwater  Habitats of
      the United States.   FWS/OBS-79/31.  U.S. Fish and Wildlife
      Service.

 16.   Hansen, D.J., J.  Cardin, L.R. Goodman, and G.M.  Cripe.
      1985.  Applicability of Site-Specific Water Quality Criteria
      Obtained Using  the Resident Species Recalculation Option.
      Internal report,  U.S.  EPA, Narragansett, Rhode Island and
      Gulf Breeze,  Florida.

 17.   American Society for Testing Materials.  1988.   Standard
      Guide for Conducting Acute Toxicity Tests  with Fishes,
      Macroinvertebrates, and Amphibians.  Standard E  729-88a,
      ASTM, Philadelphia, Pennsylvania.

 18.   Detenbeck, N.E.   1990.  Effects of Disturbance on Water-
      Quality Functions of Wetlands:  Interim Progress Report:
     January 1990.  Natural Resources Research  Institute.
      Internal report  submitted to U.S. EPA, Duluth, Minnesota.

 19.   Swan son, G.A., T.C.* Winter, V.A. Adomaitis, and  J.W.
      LaBaugh.  1988.  Chemical Characteristics  of  Prairie Lakes
      in South-central North Dakota - Their Potential  for
      Influencing Use by Fish an Wildlife.  U.S. Fish  and Wildlife
     Service Technical Report 18.

20.  Kantrud, H.A., G.L. Krapu, and G.A. Swanson.   1989.  Prairie
      Basin Wetlands of the Dakotas:  A Community Profile.  U.S.
      Fish and Wildlife Service Biological Report 85(7.28).
                                29

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21.  Stewart, R.E., and H.A. Kantrud.  1971.  Classification of
     Natural Ponds and Lakes in the Glaciated Prairie Region.
     U.S. Fish and Wildlife Service Resource Publication 92
     57p.

22.  LaBaugh, J.W.  1989.  Chemical Characteristics of Water in
     Northern Prairie Wetlands.  Pages 56-90 In A.G. van der
     Valk, ed.,  Northern Prairie Wetlands.  Iowa State University
     Press.
                               30

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                           APPENDIX A

          SOURCES USED IN SPECIES HABITAT IDENTIFICATION
                      FOR MINNESOTA MARSHES
Fishes:
     Eddy, S., and J.C. Underbill.-. 1974.  Northern Fishes.  3rd
     edition.  University of Minnesota, Minneapolis.

     Nelson, J.S.  1984.  Fishes of the World.  2nd edition.  New
     York:  John Wiley and Sons.

     Niering, W.A.  1987.  Wetlands.  New York:  Alfred A. Knopf.

     Personal Communications:
          P. DeVore and C. Richards of the Natural Resources
          Research Institute, Duluth, Minnesota.
          G. Mont2, Minnesota Dept. of Natural Resources.

Macroinvertebrates:

     Niering, W.A.  1987.  Wetlands.  New York:  Alfred A. Knopf.

     Pennak, R.W.  1978.  Fresh-water Invertebrates of the United
     States.  2nd edition.  New York:  John Wiley and Sons.

     Williams, w.D.  1976.  Freshwater Isopods (Asellidae) of
     North America.  U.S. EPA, Cincinnati.

     Personal Communications:
          P. DeVore and A. Kershey of the Natural Resources
          Research Institute, Duluth, Minnesota.
          P. Mickelson of the University of Minnesota, Duluth.
                               31

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                           APPENDIX B

          SOURCES  USED IN SPECIES HABITAT  IDENTIFICATION
                       FOR PRAIRIE  POTHOLES
Fishes:
     Kantrud, H.A., G.L. Krapu,  and G.A. Svanson.  1989.  Prairie
     Basin Wetlands of the Dakotas: "A Community Profile.  U.S.
     Fish and Wildlife Service Biological Report 85(7.28).

     Swanson, G.A., T.C. Winter,  V.A.  Adomaitis, and J.W.
     LaBaugh.  1988.  Chemical Characteristics of Prairie Lakes
     in South-central North Dakota - Their Potential for
     Influencing Use by Fish an Wildlife.  U.S. Fish and wildlife
     Service Technical Report 18.

Macroinvertebrates:

     Broschart,  M.R. and R.L Linder.  1986.  Aquatic
     invertebrates in level ditches and adjacent emergent marsh
     in a South Dakota wetland.   Prairie Nat. 18(3):167-178.

     Eddy,  S. and A.C. Hodson.  1961.   Taxonomic Keys to the
     Common Animals of the Northcentral States.  Minneapolis:
     Burgess Publishing Co.

     Krapu,  G.L.   1974.  Feeding ecology of pintail hens during
     reproduction.  The Auk 91:278-290.

     Pennak,  R.W.   1978.  Fresh-water Invertebrates of the United
     States.   2nd edition.   New  York:   John Wiley and Sons.

     Swanson, G.A.  1984.   Invertebrates consumed by dabbling
     ducks  (Anatinae)  on the breeding grounds.  Journal of the
     Minnesota Academy of Science  50:37-45.

     van der Valk, A., ed.   1989.   Northern Prairie Marshes.
     Ames:   Iowa  State University  Press.
                               32

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        TABLE 1.   FRESHWATER NUMERIC AQUATIC LIFE CRITERIA*
  Chemical
H, T, or pH*
 Dependent
   Chemical
H, T, or pH"
 Dependent
Organochlorines:
  Aldrin
  Chlordane
  DDT
  Dieldrin
  Endosulfan
  Endrin
  Heptachlor
  Lindane
  PCBs
  Pentachlorophenol

Organophosphates:
  Chlorpyrifos
  Parathion
      pH
 Metals:
   Aluminum
   Arsenic(III)
   Cadmium             H
   Chromium(III)       H
   Chromium(VI)
   Copper              H
   Lead                H
   rMercury
   Nickel              H
   Selenium
   Silver              H
   Zinc                H

Others:
   Ammonia           pH, T
   Chloride
   Chlorine
   Cyanide
   Dissolved oxygen    T
*    Summarized from individual criteria documents.   Chemicals
     that have adjustment factors built into the criteria  are
     indicated.
**   H = Hardness, T = Temperature.
                                33

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 TABLE 2.  SUITABILITY OF WETLAND SPECIES TO FILL MINIMUM FAMILY
             REQUIREMENTS  FOR SIX CRITERION CHEMICALS
Required
Taxonomic
Group
Salmon id
Other Fish
Other
Chordate

Planktonic
Crustacean
Benthic
Crustacean
Insect
Nonarthropod-
Nonchordate
Another
Insect
or New Phylum
PCBs
NP*
Y"

Y
•

Y

Y
Y

NT*"

Y

Para-
thion
NP
Y

Y


Y

Y
Y

Y

Y

PCP
NP
Y

Y
\

Y

Y
Y

Y

Y

Cyanide
NP
Y

Y


Y

Y
A
Y

Y

NT

Zinc
NP
Y

Y


Y

Y
Y

Y

Y

Chrom-
ium (VI)
NP
Y

Y


Y

Y
Y

Y

Y

*NP    Not present:   Taxonomic group not present in most wetland
       types.
**Y    Wetland genera represented adequately.
***NT  Not tested:  Available toxicity data does not include
       sufficient wetland species.
                               34

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     TABLE 3.  SOME CONDITIONS RECOMMENDED FOR DILUTION WATER
                FOR WATER QUALITY CRITERIA TESTING17
Characteristic
Total organic carbon
Part icul ate matter
PH
Freshwater
<5 mg/L

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         TABLE 4.  EFFECTS OF COFACTOR8 OH CRXTERIOV CHEMICAL TOZZCZTT
                              COFACTORS:  Effect of Gr«*t«r Valu«
                             TOG   TURB TEMP DO   H    IOHIC 8   NUTR/ORO
Org&nochlorines:
Aldrin
Chlordane
DDT
Dieldrin
Endrin
Heptachlor
Lindane
Endosulfan
PCBs
Pentachlorophenol
Toxaphene

Organophosphates:
Parathion
Chlorpyrifos

Metala:
Arsenic (III)
Cadmium
Chromium (VI)
Chromium (III)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Aluminum

Other:
Chlorine
Cyanide
Ammonia
Chloride
DO
                                                         +    +
                                         ?    0
                                        +

                                        +?
0


-?
•y

0
+:  increased toxicity/mobility
Oi  no effect on toxicity/mobility
-:  decreased toxicity/mobility
TOC: total organic carbon
TURB: turbidity
IONIC: ionic strength/cations
                                     ?:  tested and found inconclusive
                                      :  not discussed in criteria document
                                     ±:  short-term increase/long-term decrease
                                     DO: dissolved oxygen H: hardness
                                     NUTR/ORG: nutrients/organic acids
                                     S: salinity
                                      36

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     TABLE 5.   WATER CHEMISTRY FOR SELECTED MINNESOTA MARSHES*
          ,._                                  Comparison with
Water Quality                                 Standard Testing
Characteristic      Mean Value      Range      Conditions
  pH (pH  units)        7.1          6.1-7.6     Within range
  Total organic
     carbon  (mg/L)      20            5-60        High
  Dissolved
     oxygen  (mg/L)     8.2          0.4-15.4    Seasonally low
  Hardness           No data
(mg/L as  CaCO3)
  Alkalinity            8             4-14
(mg/L as  CaCO})
  Temperature  (°C)    11.9           0.3-31.0  Seasonal extremes
  Turbidity (NTU)       33            1 - 412
* Data taken from Detenbeck (1990), n=42 wetlands.10
                               37

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            TABLE 6.  COMPARISON OF TEST SPECIES WITH
              MINNESOTA MARSH BIOTA FOR SIX CRITERIA
Required
Taxonomic
Group
Salmonid
Other Fish*
Other
Chordate
PCBS
NPd
Micropterus
Pimephales
Parathion
NP
Lepomis
Pimephales
PCP
NP
Micropterus
Rana
Planktonic
Crustacean

Benthic
Crustacean

Insect

Nonarthropod-
Nonchordate
Another
Insect
or New Phylum

Aquatic
Plant
Daphnia

unknown
amphipod

Ishnurab


NT*



Tanytarsus



NT
Daphnia


Orconectes

Chironomus

unknown0
nematodes/
annelids


Ishnura



alga
Daphnia


Orconectes

Tanytarsus

unknown6
nematodes/
annelids

unknown
amphipod/
isopod


Lemna
                                             continued
                                38

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                        TABLE 6, CONTINUED
Required
Taxonomic
Group
Salmonid
Other Fish*
Other
Chordate
Cyanide
NP
Perca
Lepomis
Zinc
NP
Lepomis
Pimephales
Chromium (VI)
NP
Lepomis
Pimeohales
PlanJctonic
Crustacean

Benthic
Crustacean
Insect

Nonarthropod-
Nonchordate

Another
Insect
or New Phylum

Aquatic
Plant
Daphnia

unknown6
amphipod/
isopod

Tanytarsus


Physa


NT



Lemna
''Daphnia

unknown*
 amphipod/
 isopod

 Argiab
 Physa

 unknown0
 annelid/
 nematode
 Lemna
Daphnia


Orconectes
 *

Chironomus


Physa


NT



alga
a    Fish were sampled in water bodies associated with some of
     the wetlands, not in the wetlands themselves.
b    Probable or seen as an adult.
c    Unknown species from these taxa found in wetlands.  May or
     may not be similar in terms of habitat requirements, etc. to
     species used in toxicity tests.
d    Not present:  Taxonomic group not present in wetland type.
e    Not tested:  Available toxicity data does not include
     sufficient wetland species.
                                39

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    TABLE  7.   NUMBER OF SPECIES TESTED  FOR ACUTE  CRITERIA AND
        PERCENTAGE OF TEST SPECIES THAT ARE NOT FOUND IN
	MINNESOTA MARSHES OR OLIGOSALINE PRAIRIE  POTHOLES*

           Species Used to     Not Present    Not Present in
Chemical   Establish FAV**     in Marshes    Prairie Potholes
           (Total Number}      (Per cent)      (Per cent)
PCBS
Parathion
PCP
Cyanide
Zinc
Chromium (VI)
10
37
37
17
45
33
30%
43%
22%
29%
45%
27%
40%
64%
43%
65%
67%
64%
* Remainder of nei-eentaoe includes both tho«e «rusr>ie«a that are
     known to occur in these wetlands and those species that may
     occur in the wetlands,  but insufficient data are available.
**   Final Acute Value.
                               40

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           TABLE 8.  WATER QUALITY CHARACTERISTICS. FOR
                   OLIGOSALINE PRAIRIE POTHOLES*
Water Quality
Characteristic
               Mean Value
           Comparison with
          Standard Testing
Range        Conditions
  pH  (pH units)         8.9

  Total organic
      carbon  (mg/L)     No datac

  Dissolved
      oxygen  (ppm)  .    No datad

  Hardness             No data*
 (mg/L as CaCO3)

  Alkalinity            650
 (mg/L as CaCO3)

  Temperature (°C)     No data*

  Specific conductance 3568
 (/iS/cm at 25°C)
                               7.4 -  10.3'
                High
                              230 - 1300
                High
                              750 - 8000
a
b
c
d

e

t
Data summarized from Swanson et al.  (i988).19
N=27 wetlands.
Dissolved organic carbon data for Manitoba prairie  potholes
ranged from 0.4-102 mg/L, and for Nebraska,  from 20-60 mg/L
in one study and 139-440 mg/L in another study.22
Winterkill, caused by low dissolved oxygen under ice,  occurs
in many of these lakes.
An estimate of hardness based on alkalinity  values  gives a
mean of 760 mg/L as CaCO,.
Region is characterized by very cold winters and warm
summers.
                                41

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            TABLE 9.  COMPARISON OF TEST SPECIES WITH
              PRAIRIE POTHOLE BIOTA FOR SIX CRITERIA
Required
Taxonomic
Group
Salmonid
Other Fish
Other
Chorda te
Planktonic
Crustacean
Benthic
Crustacean
PCBs
NP
Pimephales
NT
Oaphnia
Gammarus'
Parathion
NP
Pimephales
Pseudacris*
\
Daphnia
Gammarus'
PCP
NP
Pimephales
Rana*
Daphnia
Hyalella
Insect
Nonarthropod-
Nonchordate
Another
Insect
or New Phylum
Aquatic
Plant
damselfly5
NT
Tanytarsusb
NT
Peltodytes
   >
tubificid
wormb
Chironomus
Tanytarsus6
tubificid
wormb
Physa
Microcystis    Lemna
                                42

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                        TABLE 9, CONTINUED
Required
Taxonomic
Group
Salmonid
Other Fish
other
Chordate
Cyanide
NP
Pimephales
NT
Zinc
NP
Pimephales
NT
Chromium (VI)
NP
Pimephales
NT
Planktonic
Crustacean

Benthic
Crustacean

Insect

Nonarthropod-
Nonchordate

Another
Insect
or New Phylum

Aquatic
Plant
Daphnia


Gammarus*

Tanytarsusb


Physa"


NT



Lemna
Oaphnia


Gammarus'

Argiab


Physa"


tubificid
worm6


Lemna
Daphnia


Hyalella

Chironomus1


Physa"


damselfly5



Nitzschia
a    Genus is present in the wetlands; may not be same species.
b    Species representative of that taxonomic group from criteria
     testing lists probably present in prairie potholes, but no
     actual data available.
                                43

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